- COGR’s FAQ’s and Resources on COVID-19’s Impact to Federal Awards:
- FAQs Regarding COVID-19's Impact to Federal Awards (V.2.1)
- COGR COVID-19 AGENCY MATRIX (UPDATED 05.14.2020)
- Agency Guidance Specific to Federal Award Impact: This link will provide guidance and links to information from important Federal Agencies including the Office of Management and Budget (OMB), National Institutes of Health (NIH), the National Science Foundation (NSF), and various other agencies.
- Institutional Guidance: This link provides for a listing of over 50 higher education institutions and their websites and contacts pertaining to efforts relating to their COVID-19 response.
- Additional Resources: This link will provide other resources including external links to the World Health Organization, Centers for Disease Control, Department of State Travel Advisories, etc.
- OMB M-20-11, Dated March 9, 2020: Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19)
- OMB M-20-17, Dated March 19, 2020: Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations
- OMB M-20-18, Dated March 20, 2020: Managing Federal Contract Performance Issues Associated with the Novel Corona Virus (COVID-19)
- Contracts: Contracts must be handled on a case by case basis. Details regarding any contract must be directed to the cognizant Contracting Officer. Salary changes must be handled by the contracting officer.
- Reporting: If your institution is unable to complete and submit financial and Research Progress Performance Reports (RPPR) by the scheduled due date, due to the effects of COVID-19, please be sure to contact the assigned grants management and/or program official to let them know the reports will be late.
- Salaries: If a recipient organization’s policy allows for the charging of salaries and benefits during periods when no work is performed due to the effect of COVID-19, regardless of the funding source, including Federal and non-Federal, then such charges to NIH grant awards will be allowable.
- Stipends: Institutions affected by COVID-19 may continue to provide stipend payments to fellows and trainees who may be unable to work as a result of or related to COVID-19. Recipients should notify the assigned grants management official, and provide documentation demonstrating the effect of COVID-19, and how long the institution will be affected.
- Travel and Conferences: Non-refundable costs associated with grant-related travel that has been cancelled due to COVID-19 may be charged to the NIH award if they would have otherwise been allowable. Non-refundable registration fees for conferences, symposiums or seminars that have been cancelled due to COVID19 may be charged to the NIH award if they would have otherwise been allowable.
- Final Reporting and Closeouts: NIH will allow recipients that are affected by COVID-19 to delay submission of any final financial, performance, and other reports required by the terms and conditions of award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the recipient to the agency. This delay may not exceed one year.
- Reporting: NSF has automatically extended the due date for submission of all annual project reports due between March 1 and April 30, 2020, by 30 days.
- Salaries and Stipends: Recipients are authorized to continue to charge salaries, stipends, and benefits to currently active NSF awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. The recipient also is authorized to charge other costs to NSF awards that are necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project.
- Travel and Conferences: Recipients who incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the public health emergency, are authorized to charge these costs to their award without regard to 2 CFR § 200.403. Recipients may charge the full cost to the award when the event, travel, or other activities is conducted under the auspices of the grant.
- No-Cost Extensions: Recipients must follow standard policies and procedures specified in the NSF Proposal and Award Policies and Procedures Guide (PAPPG) Chapter VI.D.3, and applicable award conditions regarding submission of grantee and NSF-approved no-cost extensions.
- Final Reporting and Closeouts: NSF has automatically extended the due date for submission of all final project reports and Project Outcomes Reports due between March 1 and April 30, 2020, by 30 days.
- Indirect Rates: Recipients may continue to use the currently approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) to recover their indirect costs on Federal awards. Recipients may request an extension on the use of the current rates for one additional year without submission of an indirect cost proposal.
- Reporting: If the lead principal investigator (PI) or the applicant institution are subject to a quarantine or a closure, progress reports for grants, cooperative agreements, and interagency awards may be submitted through the PAMS website at https://pamspublic.science.energy.gov as soon as practicable.
- Rebudgets: If the principal investigator (PI) or the applicant institution are subject to a quarantine or a closure, revised budgets and public abstracts may be submitted through the P AMS website at https://pamspublic.science.energy.gov as soon as practicable. The Office of Science will not consider changes to planned travel caused by the cancellation of meetings, quarantines, closures, or other public health measures to be a change in the scope of an award requiring agency prior approval. Rebudgeting funds that does not create a change in scope does not require agency prior approval.
- Travel and conferences: If a meeting has been cancelled, awardees must follow their institutional travel policies to determine whether costs may be charged to an award. If institutional policy permits travelers to purchase nonrefundable items (airfare, lodging, or other) and does not require travelers to reimburse the institution for change or cancellation fees, such fees may be if charged to an award. If institutional policy prohibits the purchase of nonrefundable travel or travelers are required to reimburse the institution for change or cancellation fees, such fees may not be charged to an award.
- Deadlines: An institutional declaration requiring staff telework, in and of itself, will not warrant a deadline extension. There must be further complications that make the original deadline impossible.
- Source: Accommodating Interruptions from Coronavirus Disease 2019
Office of Justice Programs, Department of Justice (DOJ):
- Interruptions in performance of grant work: You should direct any questions about allowability of costs to your OJP grant manager, or to OJP’s Office of the Chief Financial Officer by calling the Customer Service Center at 1-800-458-0786 (TTY: 202-616-3867), or via email at email@example.com.
- Award Extensions: most OJP awards may be eligible for one no-cost extension of up to 12 months. If the grant has previously received a no-cost extension and an additional extension will be requested due to the extenuating circumstances, refer to the DOJ Grants Financial Guide for additional information and consult with your grant manager as needed.
- Travel and conferences: Grantees should contact their OJP grant managers to address issues resulting from postponed or canceled meetings, such as using grant funds to cover hotel or travel related cancellation fees and penalties.
- Grantees should try to have the airline reimburse the canceled ticket(s) in cash. However, if the airline will only refund the cancellation as a credit: The grantee should apply the credit to a future trip for the same OJP grant or project. If that is not possible, the grantee should use the credit for another OJP program or project and reimburse the original OJP grant or project with the equivalent dollar amount. If neither of those options is possible, then the grantee should process the trip as a cancellation, which OJP approves to be charged to the grant due to this mitigating circumstance.
- Source: OJP Grantee Update #1 COVID-19 Impacts
Defense Advanced Research Projects Agency (DARPA):
- Interruptions in performance of grant work: Document the delay, the impact to your project, what caused it, what you did or have done to mitigate the delay, and any other relevant facts and details. As soon as possible, contact your Grants Officer in writing. Explain all facts and details of the situation, provide documentation, and be sure to note that COVID-19 is one of the reasons for your modification request.
- Incurring Additional Costs: Always carefully document any incurred costs and any relevant facts and details about what caused them. As soon as possible, email your Grants officer. In your email, relay all the pertinent facts so the Government can answer your inquiry as soon as possible.
- Travel Procedures: You are required to follow the terms and conditions of your grant, including any guidance on travel costs and reimbursement. Abnormal or additional transportation costs due to COVID-19 disruptions will be evaluated on a case-by-case basis.
- Source: Frequently Asked Question (FAQ) about COVID-19 (Coronavirus) for DARPA Performers
Department of Defense (DOD):
- Reporting: the DOD will allow grantees to delay submission of financial, performance and other reports on currently-active award accounts up to three months beyond the normal due date.
- Travel Procedures: The DOD will allow nonrefundable travel expenses incurred for travel canceled due to COVID-19 to be charged to active awards.
- Salaries: the DOD will allow recipients to continue to charge salaries and benefits to currently active awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, federal and non-federal. DOD components may allow other costs to be charged to federal awards necessary to continue work on a project even if in a period where primary research activities are limited or curtailed. To the maximum extent practicable, recipients will be expected to invoke or institute any and all reasonable mitigation actions and practices to lessen the cost to the government during the crisis period.
- No-cost Extensions: No-cost extensions will be supported in all possible cases. Please contact the DOD grants manager for award-specific guidance.
- Source: Frequently Asked Questions for DOD Research Proposers and Awardees Impacted by the Novel Coronavirus
United States Army Medical Research Acquisition Activity (USAMRAA):
- No-cost Extensions: USAMRAA’s terms and conditions of award already allow for a one-time, no cost extension of up to 12 months, without need to request prior approval, when the recipient notifies the Grants Officer (GO).
- Salaries and other costs: Recipients may continue to charge salaries and benefits to currently active awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. USAMRAA will allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project.
- Travel and conferences: USAMRAA will allow recipients who incur costs related to the cancellation of events, travel, or other activities necessary and reasonable for the performance of the award, or the pausing and restarting of grant funded activities due to the public health emergency, to charge these costs to their award. USAMRAA will allow recipients to charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant.
- Reporting: Recipients may delay submission of financial, performance and other reports on currently active award accounts up to three (3) months beyond the normal due date.
- Indirect Rates: Recipients may continue to use the currently approved indirect cost rates (i.e., predetermined, fixed, or provisional rates) to recover their indirect costs on Federal awards.
- Final Reporting and Closeouts: Recipients may delay submission of any pending financial, performance and other reports required by the terms of the award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the grantee to the GO. This delay in submitting closeout reports may not exceed one year after the award expires.
Department of the Air Force (DOAF):
- No Cost Extensions: A no-cost extension (NCE) for existing assistance award(s) may be required. The Department of the Airforce may extend awards which are active as of March 31, 2020 and scheduled to expire prior or up to December 31, 2020, at no cost for a period of up to twelve (12) months. Upon the Recipient’s business office request, the NCE will be issued per grant modification for the respective grant. The NCE is not official until you receive a grant modification signed by the Grant Officer.
- Any award that expires beyond December 31, 2020 that requires a no cost extension will be examined as the need arises.
- If recipient requires a NCE, please contact in writing to the Program Officer (using the appropriate email), Grants Officer, and RT.AdminSupport@us.af.mil.
Food and Drug Administration (FDA):
- Changes to Clinical Trials: Sponsors and clinical investigators are encouraged to engage with IRBs/IEC as early as possible when urgent or emergent changes to the protocol or informed consent are anticipated as a result of COVID-19. Since trial participants may not be able to come to the investigational site for protocol-specified visits, sponsors should evaluate whether alternative methods for safety assessments (e.g., phone contact, virtual visit, alternative location for assessment, including local labs or imaging centers) could be implemented when necessary and feasible, and would be sufficient to assure the safety of trial participants.
- Source: FDA Guidance on Conduct of Clinical Trials of Medical Products during COVID-19 Pandemic
Health Resources & Services Administration (HRSA):
- General Office Supplies: HRSA recommends grant recipients first consult their organizational policies and procedures for suitability to work from home, potential acceptable grant duties while working from home, and processes for reimbursements. Allowable costs awarded under a HRSA grant, would be permissible for reimbursement to an employee approved to work on grant duties at home (due to COVID-19; Ref: 2 CFR § 200.403, 2 CFR § 200.404, 2 CFR § 200.405) in accordance with; the Uniform Administrative Requirements, Federal cost principles, audit requirements for HHS awards (45 CFR Part 75) and consistent with the recipients organizational policies and procedures.
- Re-budgeting into an approved budget category up to 25% of the total grant funds are allowable following standard grant policy. Revisions to budgets that exceed 25%; require a Prior Approval request. We anticipate these costs/activities will be short-term, for the duration of the COVID-19 and not a long term situation.
- Recipients should not assume additional funds will be available should the charging of the unexpected expenses result in a shortage of funds to carryout approved project activities. Award recipients must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management.
- Salaries: Per guidance issued by Office of Management and Budget (OMB) Memo M-20-11 and M-20-17, HRSA recipients may continue to charge salaries and benefits to currently active awards consistent with their organization's policy of paying salaries under unexpected or extraordinary circumstances from all funding sources, federal and non-federal. If recipients do not have such policies in place for paying salaries under unexpected or emergency circumstances, they should immediately develop and officially adopt these new policies.
- Travel and Cancelations: Per guidance issued by Office of Management and Budget (OMB) Memo M-20-17, HRSA recipients may charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant. Recipients should not assume that additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel.
- Financial and Final Reports: OMB Memo M-20-17 authorizes awarding agencies to allow grantees to delay submission of financial, performance and other reports up to three months beyond the normal due date.
- Source: HRSA COVID-19 Grantee Frequently Asked Questions
American Heart Association (AHA):
- Reporting: Currently pending deadlines to submit scientific progress reports and patient recruitment/retention reports should proceed in a timely manner. The AHA is not extending these deadlines at this time.
- No-Cost Extensions: No-cost-extensions (NCE) are available as always. Please submit a Change Request in Grants@Heart. Awards currently on NCE may qualify for additional extensions.
- Salaries: AHA will also allow payment of salaries on grants and fellowships for up to 60 days without pre-approval during periods of work stoppage.
- Cancelled Travel: Unrefunded charges (conference registration, airline ticket, etc.) incurred with the intent to attend a scientific conference that was subsequently cancelled can be charged to an AHA grant.
- Source: Notice to AHA Research Community Regarding COVID-19
National Aeronautics and Space Administration (NASA):
National Institute of Food and Agriculture (USDA):
Department of Health and Human Services (DHHS):